Privacy Policy

Effective date: 2026-04-07

This Privacy Policy applies to the website operated by D2MA Limited and is intended to describe our practices in relation to the collection, use, and handling of personal data through this website.

1. Our approach to privacy

D2MA Limited is committed to handling personal data responsibly and in accordance with applicable law in Hong Kong, including the Personal Data (Privacy) Ordinance (Cap. 486) of Hong Kong, as amended from time to time.

2. What personal data we may collect

We may collect personal data that you choose to provide to us, including:

• name
• company name
• email address
• subject line and message content submitted through our enquiry form
• any other information you choose to include in your communications with us

We may also collect limited technical information through normal website operation, such as browser type, device information, IP address, and basic usage information, whether directly or through service providers used to host or secure the website.

3. Purposes of collection

We may collect and use personal data for purposes including:

• responding to enquiries and communications
• assessing possible business, partnership, consultancy, or venture opportunities
• operating, maintaining, and securing the website
• internal administration and record-keeping
• complying with legal, regulatory, or compliance requirements

We will generally only use personal data for the purpose for which it was collected or for a directly related purpose, unless otherwise permitted or required by law.

4. Provision of data

You are not generally required by law to provide personal data to us through this website. However, if you choose not to provide certain information, we may not be able to respond to your enquiry or assess your request properly.

5. Disclosure and transfer

We do not sell personal data. We may disclose personal data on a need-to-know basis to:

• service providers involved in website hosting, infrastructure, communications, or operational support
• professional advisers, including legal, compliance, or accounting advisers
• government, regulatory, law enforcement, or judicial authorities where required or appropriate by law

Some service providers may process data outside Hong Kong. Where relevant, we will take reasonable steps to ensure personal data is handled with appropriate safeguards.

6. Cookies and analytics

This website may use cookies or similar technologies for basic performance, security, analytics, or user experience purposes. You may manage cookies through your browser settings, although disabling certain cookies may affect site functionality.

7. Data security

We take reasonable steps to protect personal data against unauthorised or accidental access, processing, erasure, loss, or use. However, no internet transmission or storage system is entirely secure, and we cannot guarantee absolute security.

8. Retention

We retain personal data only for as long as is reasonably necessary to fulfil the purpose for which it was collected, or as otherwise required or permitted by law, regulation, or legitimate business need.

9. Direct marketing

We do not intend to use your personal data for direct marketing unless we have complied with applicable Hong Kong legal requirements, including obtaining any consent required under the Personal Data (Privacy) Ordinance.

10. Your rights

Under the Personal Data (Privacy) Ordinance, you may have the right to request access to personal data we hold about you and to request correction of that data. We may charge a reasonable fee for complying with a data access request where permitted by law.

11. Third-party websites

This website may contain links to third-party websites. We are not responsible for the privacy practices, content, or policies of those third-party sites.

12. Updates to this policy

We may update this Privacy Policy from time to time. Any updated version will be posted on this page with the effective date revised accordingly.

13. Contact regarding privacy matters

If you have any questions about this Privacy Policy, or if you wish to make a data access or correction request, please contact D2MA Limited through the contact form on this website.

Important note: This page is intended as a practical website privacy notice and should not be treated as legal advice. If D2MA’s operations expand, involve regulated activities, or adopt more extensive tracking, marketing, or international data flows, this policy should be reviewed by Hong Kong legal counsel.